Policy & Practice | Summer 2023

Streamlining Administrative Policies and Procedures

In addition to some of the big picture policies that have been discussed in prior sections, it is also essential to think about the smaller policies and procedures that have been codified in SNAP and have shown to no longer contribute to an effective or efficient program. This includes policies and procedures that take a significant amount of time for planning and administration, but rarely result in significant changes in eligibility or benefit amounts.

APHSA Farm Bill Recommendations on Administrative Policies and Procedures

Authorize a demonstration pilot to test and evaluate alternatives to the name, address, and signature minimum application requirement for SNAP. Current statute requires that any SNAP application with at least a name, address, and signature at minimum be processed. 26 With the large increases in applications being submitted online, this minimal requirement has become a greater concern as it often results in wasted administrative time if the applicant does not respond to follow up. This demonstration pilot should fund a group of states to test variations to the current requirement and should include an independent evaluation to assess the impacts of the changes on access, equity, and administrative efficiency to inform the larger group of state agencies. Eliminate the requirement for state agencies to verify applicant employment data through the National Directory of New Hires (NDNH) for SNAP eligibility. SNAP agencies are currently required to use the NDNH to verify employment data for any work registrant, however these data can be up to 7 months old and are largely more than 3 months old. In multiple states, NDNH matches result in less than 0.01% of households receiving a change in benefits or eligibility. Yet, individual states are spending upward of $1 million to pay for the necessary contracts and staff time dedicated to this match process. Fund SNAP as a true appropriation by authorizing “such sums as necessary” in the fourth quarter of the fiscal year and a first quarter advance. SNAP is yet to be funded as a true appropriation, meaning that if a government shutdown occurs or the yearly appropriation runs out early, SNAP will be left without the necessary funding to issue benefits — creating stress and uncertainty for both the administering agencies and customers. By fully funding SNAP, states would not have to go through burdensome planning processes each year, and customers would not be without benefits due to no fault of their own. Direct the Secretaries of the Departments of Agriculture and Health and Human Services to assess best practices and the feasibility of establishing standardized customer consent, data sharing, and customer rights language across SNAP and related programs. The purpose of this analysis would be to move closer to the creation of a universal consent language used across benefit programs to support better alignment in certifications in programs. This should work should engage FNS, CMS, and ACF, and result in a Report to Congress that includes clear identification of statutory policies that hinder the ability to further create this alignment. Eliminate the requirement for state SNAP agencies to collect verification prior to closing a case for individuals that indicate they are ineligible or no longer wish to pursue a SNAP application. When SNAP applicants indicate they do not qualify or no longer wish to pursue an application, current law requires state agencies to obtain documentation or collect this declaration in writing prior to closing the case. If an applicant does not provide this information, states must leave the case open and follow normal rules to request additional information for the minimum time period permitted prior to closing the case. This results in unnecessary aggravation for customers, delays in application processing timeliness, and wasted time and resources spent trying to receive this verification from the applicant. Instead, there should be a different option that still includes transparent communication with applicants, such as a letter of voluntary denial.

Policy & Practice Summer 2023 38